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Section Topics
A Cover letter
B Unearned gains, BOK and insiders.
B.1 BOK Financial Corp - Unreported Income and Tax Years
B.2 BOK Financial Corp Insiders
B.3 Robert G Heard - Cimarron Business Capital Company
1 How the fraud works
1.1 BOK's list of investments
1.2 BOK claimed venture capital investments for ineligible for businesses
1.3 Additional evidence
2 Source of evidence 2006 – 2009
2.1 Oklahoma Tax Commission auditor's questioning claim ignored
2.2 Fraudulent financial transactions
2.3 Failure to report income to avoid paying federal taxes
3 Source of evidence (partial) 2001–2005, 2010. Potentially $369 million more
3.1 Partial evidence for 2001 thru 2005
3.2 Most complete evidence January 2010
4 Tax credit programs operated in secrecy, to prevent discovery
4.1 First, a quasi-state agency
4.2 Second, OCIB was assigned sole authority
4.3 Third, Heard the president outsources OCIB to self
4.4 Heard authorizes himself $3.4 million and BOK $91 million in tax credits
5 Involved parties
5.1 Caution over confusion
6 References

Date: July 2, 2010
To: Appropriate federal and state authorities

BOK Financial Corp, Federal tax evasion, (state) tax credit fraud, and bank fraud

6. References
(A)This case involves claiming tax credits under "qualified investments" "Venture Capital" tax credits.
(A.1)tax credit program returns 20% of "qualified investments."
(A.2)For an investment to qualify requires obtaining an ownership interest in eligible industries
(B) Oklahoma Tax Commission auditors email and attachments. BOK state tax credit claims
(C)BOK or Cottonwood Valley Venture investment claims, and U.S. Securities and Exchange Commission filings
(D)U.S. Securities and Exchange Commission filings
(D1)U.S. Securities and Exchange Commission filings
(E)FDIC Call Reports
   Search for:
 Bank of Oklahoma, National Association
 One Williams Center.
 Tulsa,OK 74172
 Click on "Last financial information
(F)Federal Reserve Board filings; for 2006 thru 2009
(G)The fact that fraud is occurring under different but similar programs has attributed to considerable confusion. This particular case involves the following, commonly referred to as "Venture Capital" tax credits: Oklahoma Statute 68 § 2357.7 - Credit Against Tax for Investments in Qualified Venture Capital Companies - Pass-Through Entities;
(H)Other frauds involve the Capital Formation Incentive Act tax credit programs. Commonly known as Small Business and Rural Venture, each having to two subcategories and can be found at.
(H.1)Small Business Capital Formation Incentive Act. Statute 68 2357.60 through 2357.65A.
(H.2)Rural Venture Capital Formation Incentive Act. Statute 68 § 2357.71 thru 2357.76A.
(J)Oklahoma Capital Investment Board Management Agreement.
(K)Oklahoma Capital Investment Board Audit.
(L)Cimarron Business Capital Company

Notes: View

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